In this newsletter, the Compensation Office informs you about important decisions, innovations and publications on the subject of offsetting Switzerland's carbon emissions.
A partire dal numero 16, la newsletter è pubblicata anche in italiano:
Newsletter in English
Starting with issue 19, the newsletter is also published in English:
- 1. New Version Mitigation Activity Summary (MAS)
- 2. Use of Validation or Verification (VV) technical experts and personnel changes
- 3. Forward action requests (FARs) from previous verification periods must be processed by the validation and verification bodies (VVs).
- 4. Guidelines for cookstove-related activities (Projects abroad)
- 5. Vehicles subject to carbon emission regulations cannot be included in the offset scheme.
- 6. Same treatment for financial assistance under the Impulse Programme and the Buildings Programme
- 7. Financial assistance for the production of electricity from renewable energy sources: Avoid double counting
- 8. Emission reductions by heat consumers with reduction commitment: withholding in the event of double counting
- 9. Greenhouse gas emission/efficiency target: deadlines for submitting documents
- 10. New protocol for publishing Excel files for calculating emission reductions
1. New Version Mitigation Activity Summary (MAS)
For projects abroad, a Mitigation Activity Summary (MAS) must be submitted with the application for authorization. This document has been slightly revised (project type categories adjusted and consent for publication updated) and is publicly available. Previous versions remain valid for a transitional period of three months. The Compensation Office recommends using the latest version for applications as soon as possible.
Template for compensations project (only available in English):
2. Use of Validation or Verification (VV) technical experts and personnel changes
Apart from secondary support functions, the VV undertakes to use only technical experts approved by the FOEN for validation and/or verification. This also applies to the overall manager and the quality manager.
The FOEN must be informed immediately of any changes in personnel. If the VV no longer meets the requirements of Art. 11a of the CO2 Ordinance, the FOEN may withdraw the approval.
3. Forward action requests (FARs) from previous verification periods must be processed by the validation and verification bodies (VVs).
As monitoring report verifier, a VV is required to verify the implementation of the FARs formulated in the decision regarding the qualification of a project or resulting from the last decision for issuance of attestations. The outcome of this verification must be clearly recorded in the verification report.
A VV, as validator (in the event of a crediting period extension or substantial modification), is required to verify that the FARs from the previous crediting period (or resulting from the last decision for the issuance of attestations) have been incorporated into the new project description. The VV will clearly state in the validation report how the FARs have been incorporated into the project description.
4. Guidelines for cookstove-related activities (Projects abroad)
In the case of projects abroad that involve optimised/more efficient cookstoves, it is often not possible for logistical and scheduling reasons to measure all the emission reductions. Nevertheless, emission reductions are only recognised if they are ‘verifiable and quantifiable’ (Art. 5 para. 1 let. c no. 1 of the CO2 Ordinance). In order to meet this requirement as far as possible in projects/programs of this type, the approaches and monitoring requirements formulated in the document ‘Guidelines for cookstove related activities’ should be taken into account in addition to the general requirements for compensation projects and programs of the CO2 Ordinance.
In future, the data should be collected at least on the basis of the four approaches:
- KPT: The Kitchen Performance Test (KPT) is the most important method for measuring fuel consumption in households in the field.
- Stove use monitors (SUMs), (usage rate): These sensors track cooking processes by recording the temperature of a cookstove. As soon as the cookstove temperature exceeds a certain threshold, a cooking process is recorded in the device's usage log.
- Surveys (qualitative)
- Appropriate sampling plan
The guidelines, which explain the data collection requirements for each approach, will be published on our website shortly. However, we will be happy to send them to you on request.
5. Vehicles subject to carbon emission regulations cannot be included in the offset scheme.
In Switzerland, carbon emission regulations for new vehicles apply to passenger cars and light commercial vehicles (LCVs). Heavy-duty vehicles (HDVs) will also be subject to regulations on CO2 target values for the first time in 2025.
Based on the target values established by law, each importer of passenger cars, LCVs and HDVs must comply with a target value for its fleet. To meet these target values, low-emission vehicles are imported, either as part of a fleet of vehicles/emissions pool through importation, or through vehicle assignments. The emissions reductions achieved by such vehicles cannot be included in the carbon offsetting scheme, as their ecological added value has already been compensated. Moreover, exceeding an individual fleet-specific target cannot be counted as an emissions reduction in the offsetting scheme.
6. Same treatment for financial assistance under the Impulse Programme and the Buildings Programme
Financial assistance received under the Impulse Programme must be treated in the same way as assistance under the Buildings Programme. For instance, there is no apportionment of effect for financial assistance received in connection with a grid connection under either the Buildings Programme (up to 70kW = M-07) or the Impulse Programme (over 70kW = IP-07), if Annex 3a of the CO2 Ordinance applies.
For more information on the Impulse Programme, see (Das Gebäudeprogramm > Impulsprogramm; de/fr/it):
7. Financial assistance for the production of electricity from renewable energy sources: Avoid double counting
If an offsetting project receives financial assistance under the ordinance on the promotion of electricity production from renewable energy sources (EnFV Ordinance), the following procedures must be followed:
1) Compensatory feed-in remuneration: The last positive decisions were sent prior to 2021, though some of these installations are not yet operational. All installations receiving the compensatory feed-in remuneration must comply with the minimum energy requirements (point 3). Offsetting projects in the electricity sector, such as photovoltaic (PV) installations, that receive the compensatory feed-in remuneration are not eligible for any attestation, as the ecological added value is already compensated.
2) For other support instruments, such as investment grant or operating cost contributions, non-recurrent remuneration and the new floating market premium or heat bonus (from 2025 only), the minimum requirements set out in point 3 must be met. The non-recurrent remuneration applies only to PV installations; there are no minimum requirements for heat. Electricity production supported by these instruments can receive attestations from offsetting projects (the requirements of the EnFV Ordinance must be met and included in the calculation of reference scenario emissions).
3) For heat projects with a heat source receiving financial assistance under the EnFV Ordinance, only the emissions from the reference scenario that exceed the minimum requirements can receive attestations:
a. Projects applying Annex 3a of the CO2 Ordinance (from 30.11.2023): The minimum requirements are included in the standard emission factor, so no 'corrections' are needed when calculating emission reductions.
b. Projects applying Annex 3a of the CO2 Ordinance (up to 30.11.2023): The minimum requirements for the compensatory feed-in remuneration are accounted for by a factor in the formula. For all other instruments under the EnFV Ordinance, the minimum requirements need not be considered until the end of the crediting period, unless otherwise specified in the project description. The applicant must calculate the reference scenario emissions up to the end of the crediting period, as set out in the project description. If financial assistance is granted after registration and has not been disclosed in the project description, it may constitute substantial modifications (Art. 11 CO2 Ordinance). In such cases, the project must be revalidated (Art. 8 CO2 Ordinance). The minimum requirements will be considered in the following crediting period, together with the standard emission factor (see point a).
c. Projects not applying Annex 3a of the CO2 Ordinance: The applicant must demonstrate how the minimum requirements are met and incorporated into the calculation of the reference scenario emissions. For instruments that have been disclosed in the project description, the minimum requirements need not be considered until the end of the crediting period, unless otherwise specified in the project description. The applicant must calculate the reference scenario emissions up to the end of the crediting period, as set out in the project description. If financial assistance is granted after registration and has not been disclosed in the project description, it may constitute substantial modifications (Art. 11 CO2 Ordinance). In such cases, the project must be revalidated (Art. 8 CO2 Ordinance) and the minimum requirements must be incorporated into the calculation of emissions from the reference scenario.
4) All financial assistance under the EnFV Ordinance must be considered in the economic feasibility analysis, including revenue from the sale of Guarantees of Origin (GOs). If financial assistance has not yet been granted at the time of validation, the business case must be updated at the time of the first verification and, if necessary, revalidated. Financial assistance may be estimated by the applicant.
Energieförderungsverordnung EnFV
8. Emission reductions by heat consumers with reduction commitment: withholding in the event of double counting
Emission reductions from heat consumers with a reduction commitment (in accordance with Art. 96 CO2 Ordinance) may be withheld if there is a risk of double counting (see point 10 of the 18th newsletter from the compensation office). This applies in all cases: where an applicant itself has entered into a reduction commitment, where a project included in a programme has entered into a reduction commitment, or where consumers of district heating have a reduction commitment. If it can be proven that there is no double counting, the attestations are issued.
In all cases, the applicant must present the emission reductions of the heat consumers with a reduction commitment separately to facilitate monitoring control.
9. Greenhouse gas emission/efficiency target: deadlines for submitting documents
If an applicant is also the operator of an installation with a greenhouse gas emissions/efficiency target, or if the owner of the project in an offsetting programme is the operator of an installation with a greenhouse gas emissions/efficiency target, they must submit the monitoring report and the verification report for the offsetting project simultaneously with the annual monitoring of the reduction obligation, before 31 May of the following year (Art. 9 para. 7 CO2 Ordinance). This requirement does not apply to heat consumers with a reduction commitment.
The attestations issued count as actual emissions in the greenhouse gas emissions/efficiency target. To achieve this, annual monitoring is required for the offsetting project. The deadline of 31 May of the following year must therefore be met.
An extension may be granted for monitoring data up to and including 2023. In such cases, the applicant must notify the Compensation Office via email and indicate which operators are subject to a reduction obligation.
For monitoring data from 2024 onwards, extensions will no longer be available.
For the 2025 monitoring period on, the 31 May deadline is extended to 31 August from 2026. After this date, no attestations will be issued, as they will no longer count towards the greenhouse gas efficiency target, and double counting cannot therefore be ruled out. These attestations will not be issued retrospectively.
10. New protocol for publishing Excel files for calculating emission reductions
In accordance with Article 14 of the CO2 Ordinance, the FOEN may publish the project description, validation report, verification report and monitoring report, while preserving manufacturing and business secrets.
As the Compensation Office understands it, the annexes to the project description and monitoring report are part of these documents, but so far were not published.
The publication procedure has been revised as follows: the Excel files containing emissions reduction calculations, if included in the documentation, can also be published. If applicants have manufacturing or business secrets in their documents, they must redact these after providing justification.
Last modification 26.02.2025